GAWDA FDA Compliance Alert (May-3-2015)

OSHA GHS Compliance and CGA C-7-2014

Compliance Alert –OSHA GHS Compliance For Medical Gas Cylinders

Q – Must we remove the existing medical gas label under the epoxy clear-coat on small Oxygen, USP cylinders?

A – GAWDA recommends that its members follow CGA C-7-2014, Guide to Classification and Labeling of Compressed Gases for labeling of compressed gas containers. C-7 was updated in 2014 to address GHS requirements.

For many years, the medical gas industry has successfully worked with the FDA on the appropriate labeling material for medical gas cylinders. Fortunately for us, the FDA accepts CGA C-7 in lieu of the agency’s much more difficult labeling regulations (21 CFR 201).

Please direct questions to:
Tom Badstubner, GAWDA Medical Gas Consultant –, or Mike Dodd, GAWDA DOT/OSHA/EPA Consultant –



This is information was developed to assist GAWDA members in complying with government regulations; it does not constitute legal advice, and users are advised to obtain legal counsel to develop their individual compliance programs. Additionally, GAWDA does not guarantee that use of this material will ensure compliance with any regulatory or legal standard.

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